implementation of coc

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ABSTRACT. More and more organisations formu-

late a code of conduct in order to stimulate respon-

sible behaviour among their members. Much time and

energy is usually spent fixing the content of the code

but many organisations get stuck in the challenge of

implementing and maintaining the code. The code

then turns into nothing else than the notorious paper

in the drawer, without achieving its aims. The chal-

lenge of implementation is to utilize the dynamics

which have emerged from the formulation of the

code. This will support a continuous process of reflec-

tion on the central values and standards contained in

the code. This paper presents an assessment method,

based on the EFQM model, which intends to support

this implementation process.

KEY WORDS: assessment method, business ethics,

code of conduct, continuous improvement, learning

organisation, quality management, responsible organ-

isation, self-evaluation

1. Introduction

During the last decade of the twentieth century,

the debate around corporate social responsibility(CSR) seemed to intensify. The responsibilities

of organisations are no longer addressed onlyby trade unions and environmental lobbies. In

particular, new groupings such as employees,

customers, managers, economists, shareholdersand public servants are taking up the subject

Measuring the Implementation

of Codes of Conduct. An

Assessment Method Based

on a Process Approach of

the Responsible Organisation

Journal of Business Ethics 45: 6578, 2003. 2003 Kluwer Academic Publishers. Printed in the Netherlands.

Andr Nijhof is an assistant professor at the faculty ofBusiness, Public Administration and Technology of theUniversity of Twente, Enschede, the Netherlands.Stakeholder theory, ethics of care and organisationalchange management are important theoretical notions inhis research. Nijhof has published in journals like theInternational Journal of Value Based Management, Journal of Business Ethics and the Leadership andOrganisation Development Journal, besides several pub-lications in Dutch books and journals. Next to the

assignment at the University of Twente Nijhof is workingat the management consultancy firm Q-Consult inArnhem.

Stephan Cludts is researcher at the Centre for Economicsand Ethics of the Catholic University of Leuven,Belgium. He defended a Ph.D. on employee participa-tion in which he blended notions of business ethics andhuman resources management. His research interestsextend to stakeholder theory, ethics of leadership andsocial capital.

Andre Nijhof

Stephan CludtsOlaf Fisscher

Albertus Laan

Olaf Fisscher is Professor of Quality Management andBusiness Ethics at the University of Twente in theNetherlands. His area of research focuses on responsiblemanagement in innovation processes. Fisscher is theauthor of many articles and books on organisationalvalues, quality management and management of tech-nology and innovation, including Social-dynamicalaspects of quality management in NPD (2000) and

The myth of self-managing teams; A reflection on theallocation of responsibility between individuals, teamsand the organisation (1999).

Albertus Laan had recently finished his graduation thesison the implementation of codes of conduct. He is workingon a Ph.D. about the responsabilisation of firms in theDutch construction industry. He is especially interestedin views on human morality and decision making. Hehas published an article on the responsible organisationin the journal Management & Organisatie.


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of corporate social responsibility (CSR)

(Donaldson, 1995). We have seen the emergenceof strategically operating NGOs, and the appear-

ance of a European Green Paper promoting aEuropean framework for CSR. One facilitating

factor of this development is the growing scaleof organisations, combined with the fading reg-ulatory function of government, with the con-

sequence that the power of trade and industryhas increased. In reaction to their increasing

power, CSR appears to have become a broad-based societal and organisational development: at

the national and international levels we observea rapidly developing terminology from which, so

far, only a few definitions emerged as dominant.A plurality of moral conceptions, together with

an increasingly diverse society and a growingmedia influence, makes it increasingly difficult

for organisations to predict from where criticisms

will flow. This fosters the fast growth of thenumber of consultancy services being offered on

subjects such as transparency and communityinvestment. And partly as a result of these devel-

opments we see a fast growing attention for theinternal organisation of business ethics; more and

more firms are handling (configurations of)ethical tools and instruments.

Within the diverse set of management instru-ments for stimulating en monitoring responsible

behaviour, codes of conduct seem to be one of

the most widely adopted instruments. As a partof their CSR policy, 38% of the top one hundred

organisations in the Netherlands have drawn upa code of conduct. Sixty five percent of the top

five hundred organisations in Spain (Mel et al.,2000) and 50% of the largest companies in

Australia have adopted a code. The United Statesand Canada top the list with 78% and 85%

respectively of the top 1000 organisations having

drawn up a code of conduct (Kaptein et al.,2000). However, research in different countrieshas shown that, if an organisation really wants

to influence the behaviour of its staff, a corpo-

rate code of conduct is not enough: there is nodirect relation between the fact that an organi-

sation has a code of conduct and the levelof responsible behaviour within companies

(Matthews Cash, 1987; Weller, 1988; N.B.E.S.,2000). That document has to be embedded in

the processes and culture of the organisation

(McDonald and Nijhof, 1999). This need is

accentuated by the fact that the stakeholders havebecome increasingly sensitive to the difference

between words and deeds (SER, 2001).

Defining codes of conduct

Our assessment method focuses on the process of

implementing a code instead of the outcomes ofthis process. A consequence of this is that we do

not specify in our research what the contents ofa code of conduct should be. After an organisa-

tion has developed a code, our method can be

used to assess the degree to which a code of

conduct is embedded in the organisation.In our research we made certain assumptions

about the use of a code and about general

subjects addressed. Therefore, our assessmentmethod should be relevant to assess the embed-

dedness of any of code which meets the fol-lowing assumptions:

The code contains both open guidelines

about desirable behaviour (value orienta-tion) and closed guidelines pointing at pro-

hibited behaviour (compliance orientation);

The code relates both to the behaviour ofindividual employees and to the collectivebehaviour of the organisation as a whole;

The code indicates how responsibility isdistributed within the firm;

The code is used as an instrument

enhancing corporate social responsibility.

If these assumptions are not met completely by

any particular code, some parts of our assessmentmethod will not be applicable.

Functions of a code of conduct

Writing a code of conduct has undoubtedly the

advantage of setting managers to think about thecentral values of their company and to reflect on

situations in which these values are at stake.However, we consider CSR to acquire its sub-

stance through the behaviour of people withinorganisations (Goodpaster, 1989). The managers

66 Andre Nijhof et al.


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themselves represent only a tiny minority of the

people who work for any given organisation.The implication of this view is that organisations

need to embed responsible entrepreneurshipnot only into their business strategy and policy,

but also into the organisational processes, theculture, and the daily matters.

Therefore, when a code has been drafted, the

first challenge is to trigger reflection on thecentral values proposed in the code among the

employees. In the second place, it is necessaryto link the reflection of managers and employees

in order to guide actual behaviour within theorganisation. For this to happen, the code of

conduct should be embedded in the web oforganisational processes and routines. For

example, what could be the effect of a code ofconduct if the whole management system were

oriented towards stimulating and rewarding short

term financial gain? In order to be effective, acode of conduct requires a review of the man-

agement system to make sure that employees areencouraged to work in congruence with the

code.Embedding the code of conduct can con-

tribute to the emergence not only of responsibleindividual behaviour but also of a responsible

organisation. The concept of a responsibleorganisation refers to the embeddedness of

clearly defined and prioritised responsibilities in

the strategy and policy of an organisation. Theresponsibilities of an organisation can be fulfilled

only through the daily behaviour of its staff andmanagement, but an organisation needs to trans-

late its CSR philosophy into supportive man-agement instruments and processes in order to

become a responsible organisation. As it isable to attract managerial attention in this way,

responsibility becomes an explicit management

criterion, next to others such as efficiency, flex-ibility and quality (Fisscher et al., 2001).

The assessment method focuses on the dif-

ferent processes that are necessary, on the one

hand, to stimulate reflection across all the layersof the organisation on the issues and responsi-

bilities mentioned in a code of conduct, and onthe other hand to stimulate actual behaviour in

accordance with the code as it is understoodthrough the reflection process just mentioned.

Within the structure and culture of an organisa-

tion, many barriers to reflection and action exist.

Defining these barriers and dealing with them isalso an important part of the assessment method.

The different processes are operationalised

within a questionnaire to be used for self assess-ment by the organisation concerned. Our assess-ment method produces an overview of the extent

to which the organisation actively manages theprocesses necessary for the implementation of a

code of conduct. The identification of the dif-ferent processes and their operationalisation in

the assessment method is based on a literature

study and a comparison with other initiatives inthis field.

2. A process approach of codes of

2. conduct

A code of conduct is an instrument for respon-

sibilisation within the organisation, but it isin itself not sufficient to shape a responsible

organisation. In order to understand this, it isuseful to distinguish the different processes which

shape responsible behaviour within the organi-

sation; we call them processes of responsibilisa-tion. Within the framework of the Inclusive

Innovation research project, we distinguish sixprocesses of responsibilisation (see Figure 1): the

process of coding, the process of internalisation,the process of identifying and removing barriers,

the process of enacting values, the process ofmonitoring and the process of accountability.

These processes have been defined in the firstplace on the basis of learning models such as

those developed by Kolb (1984) and Van der Bijet al. (2001). Their models include four broadly

similar stages: (1) gathering information or expe-

rience, (2) reflecting on that information orexperience and comparing it with previous

norms or concepts, (3) developing of new normsor concepts and (4) experimenting with these

new norms or concepts. Stage four generates newinformation or experience, which leads the

learning person or organisation to start with anew learning cycle. In our scheme, an organisa-

tion goes through these four stages by theprocesses of coding (stage 1), identifying and

Measuring the Implementation of Codes of Conduct 67


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removing barriers (stages 2 and 3) and enactingvalues (stage 4). We have formulated these

processes so as to stress the fact that the man-agement has the possibility to act upon them.

In the second place, it was necessary to enrichthis model with processes reflecting the interac-

tion between the management (who is supposedto lead the introduction of the code) and the

employees (whose collaboration is necessary in

order to give meaning to the code). This lead usto define two additional processes: the process

of internalisation, whereby the employees areconfronted with the code developed by the

organisation (whatever that may entail), and the

process of monitoring, whereby the managementobserves the extent to which the employees liveby the code. Those processes allow the manage-

ment not only to intervene when employeesdisplay undesired behaviour, but also to adjust the

organisational values or their translation in theprimary processes of the firm. In this way, these

processes truly reflect an interaction between themanagement and the employees, whereby both

parties can influence each other mutually. We

have also formulated these processes, as theprevious ones, such that they could be recognised

and steered by managers willing to enhanceresponsible behaviour in their organisation.

In the third place, we have added a sixthprocess, the process of accountability, which

reflects our conception of responsibility asresponsibility towards the different stakeholders

of the firm. The public justification of behaviourshould be an integral part of the conduct of

business. Therefore, an assessment of responsible

behaviour in the firm should not be limited toan assessment of employee and management

behaviour. It must include a dialogue with the

stakeholders. This dialogue is conducted not onlyat the coding stage, but also as part of a regularreview of the firms performance with regard to

the expectations of its stakeholders.

Model for implementing codes of conduct

We end up with the following sequence of

processes to be gone through in order to develop


Figure 1. Processes for the implementation of a code of conduct.


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responsibility. First, it is essential to determine

what function a code of conduct should have.What risks or barriers exist within an organisa-

tion which obstruct responsible behaviour?Particular care needs to be taken of processes,

customs or attitudes which hinder the applica-tion of certain values and norms: these are thebarriers, which need to be identified and

removed. Second, it is necessary to code onesvalues, i.e. to shape and recognize ones identity,

which is expressed through a code, whichincludes a mission statement and a list of core

values. This process of coding is done in dialoguewith key stakeholders and, indeed, with the

members of the organisation. Third, all theemployees need to appropriate the code which

defines the corporate identity. Such appropria-tion goes further than simply agreeing on a list

of values; it entails translating the code in terms

which are meaningful to the employees in theirdaily activities as members of the organisation.

This may require an introduction to the code,dilemma training, focus groups and so on.

Fourth, the employees have to enact the code.We define enactment as an integral process of

responsibilisation, and not as the output of aseparate responsibilisation process, in order to

stress the fact that behaving according to the codeis itself instrumental to further internalise the

code and to refine it wherever necessary. Indeed,

the fifth process (monitoring) does not only referto controlling the application of the code and

sanctioning possible deviations, but also to under-stand the causes of such deviations, which are

likely to call for adaptations of employee behav-iour as well as adaptations of the code. Sixth,

the process of accountability covers the commu-nication between the organisation and its stake-

holders about the way the organisation has taken

up its responsibility, whereby necessary adapta-tions of the code are already envisaged, whichleads ultimately to a new coding round.

Obviously, these processes are closely con-

nected to each other and indeed they are notstrictly sequential. For instance, after a critical

incident occurred, the identification of thebarrier to responsible behaviour which allowed

the incident to occur may lead directly to aprocess of coding. These processes unfold in

repeating and overlapping cycles. At the same

time, each of these processes separately con-

tributes considerably to stimulating responsiblebehaviour. If one or several processes are not

filled in, the integration of the code of conduct

is at risk.Let us note one more thing about these six

processes of responsibilisation: they contribute

not only to enhancing organisational responsi-bility, but also to enhancing the moral compe-

tence of individuals within organisations. It isobvious to us that an organisation cannot be

responsible if its members are not, but we want

to stress that the processes defined here do notassume a certain level of moral consciousness

among the employees. On the contrary, these

processes support the reflection on differentresponsibilities and stimulate putting reflectioninto action in order to become responsible

members of the organisation.

EFQM management model

The definition of these six processes of respon-

sibilisation is useful to understand that a code of

conduct is not in itself sufficient to shape aresponsible organisation. The code, as a static

document, represents only a part of the firstprocess. In contrast, we claim that if an organi-

sation wishes its codes of conduct to be appliedand embedded in its daily procedures, it should

use the code as the starting point from which tomanage these six processes of responsibilisation.

Further, we suggest that the EFQM model (themodel defined by the European Foundation for

Quality Management), which is a widely used

business model in relation to total quality man-agement, is useful to manage these six processes.

The EFQM model is used as an instrument facil-itating continuous improvement. In order to

encourage progress with regard to responsiblebehaviour, it is desirable that the CSR policy

would be very much in line with models suchas the EFQM model.

The EFQM model was developed in the early1980s by large multinationals with the purpose

of integrating quality in organisations. Thosemultinationals were looking for an instrument



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Figure 2. Analysis of the six processes of responsibilisation based on a self evaluation.

Figure 3. Analysis of the organisational areas based on a self evaluation.


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will report here the first case-study, which was

performed at the municipality of Amsterdam.Though on the first glance this case might seem

relatively distant from mainstream for-profit

organisations, the implementation of its code ofethics posed very relevant and interesting chal-lenges to the leadership of the municipality.

The code of the municipality sets unique standardsto be applied in diverse settings

Over 22.000 employees work for the munici-pality of Amsterdam, in fourteen city boroughs

and about forty departments which operate on

widely varied domains and relatively indepen-dently from each other. Each head of department

and each district officer is responsible for imple-

menting the integrity policy in his or her depart-ment or district and several departments havetheir own codes. The municipality developed a

code for the entire organisation in order tosupport the integrity of the employees of the

municipality (i.e. civil servants).1 This codecontains a set of rules which specify clearly

which behaviour is acceptable and which is not.

The code was officially communicated to allemployees in January of 2002. With the intro-


Figure 4. Indicators of embeddedness in the area of processes (examples).

Figure 5. Indicators of the internalisation processes (examples).


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duction of its code of conduct, the municipality

explicitly expressed its intention to clarify thelegitimate expectations of the stakeholders,

mainly the wider public and the civil servants.This clarification implies an harmonisation of

the procedures and values adopted by thevarious departments. As a consequence, the codecontains basic values and guidelines which should

prevail throughout the municipal services. Clearguidelines contribute to protect the interests

of the public, but also the managers and theemployees of the municipality. The departments

which had their own code needed to adapt thoseto meet the standards set by the overarching code

of the municipality.

The code of the municipality is part of a widerintegrity policy

The municipality of Amsterdam decided to

develop a code of conduct in 1998, after a seriesof fraud and corruption incidents which had

been widely publicised in the media (GemeenteAmsterdam, 2000). The code is one element of

the integrity policy of the municipality, whichaims primarily at preventing future occurrences

of fraud and corruption, and stimulating adequatebehaviour when the civil servants face such cases.

The code is but one element of that integrity

policy, which includes in addition mandatoryself-assessments by each department and each

district of the municipality (these self-assessmentsare conducted according to a methodology devel-

oped by the national Security Office) and inde-pendent risk audits.

As the mandatory self-assessments lead to theconclusion that the integrity policy needed

improvement in virtually all departments and dis-

tricts, a Bureau of Integrity (BI) was set up in2001 with the task to facilitate the implementa-tion of the code in the various departments of

the municipality. The Bureau of Integrity has

a support function and employs (anno 2002)fifteen employees with complementary exper-

tises: researchers, legal and forensic experts,auditors, communication specialists and trainers.

The Bureau of Integrity offers all departments anumber of activities and methodological instru-

ments to support integrity. These instruments

include:

preventive analysis of the activities which

generate risks of breach of integrity;2

internal audit of the quality of the organi-sation of the integrity policy;

advice about the improvement of proce-

dures and rules with regard to integrity (e.g.consultation procedures in the works

council, appraisal interviews, functioninginterviews and personal development);

activities aiming at relating the integritypolicy to the Planning and Control cycles;

training employees about integrity and pro-fessional responsibility;

facilitation of strategy conferences in whichdepartments define their integrity policy;

legal advice about the integrity policy of the

municipality; advice about disciplinary sanctions, disputes

and appeals against the integrity policy; an integrity help desk (internal whistle

blowing procedure) in order to report anyincident when communication with the

direct supervisor is not effective.

Output of the self-evaluation

In order to test the method of Inclusive

Innovation we had a self-evaluation with

managers of different departments and cityboroughs. We selected especially managers who

contributed actively to the implementation ofcodes of conduct. Therefore the outcomes are

not representative for the whole municipality ofAmsterdam. The main goals of the self-evalua-

tion were to test the model and to exchange

experience, to identify their respective strengthsand weaknesses and to select priority areas forfurther improvement.

The exchange of experiences was perceived

as an important added value of the evaluationsession. The self evaluation also showed that the

different departments chose many differentapproaches for implementing the common code

of the municipality. The endeavours of theBureau of Integrity are expected to lead to more



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uniform approaches in the various departments

in the future (the Bureau of Integrity has beenset up only recently).

The self-evaluation also showed that, overall,some processes of responsibilisation receive

clearly more attention than others. For instance,the process of internalisation appears to receivea lot of attention. Indeed, the management of the

municipality acknowledges that most employeesdo hardly ever read the code. In order to trans-

form the code into a living document, they needto literally bring it to life. One department

achieved that by inviting theatre actors toorganise a performance about the code. The

employees of another department do not receivethe code by post but receive it, together with a

short introduction to the code by their superior,during their first appraisal interview in order to

stress its importance. In addition, the munici-

pality summarised the key points of the code ona smart card which is distributed to all con-

tractors and temporary employees.On the contrary, the process of enacting the

code appears to be relatively underdeveloped.The self-evaluation allowed the participants to

point at some weaknesses of the integrity policywhich barred the way to effective enactment of

the code. Though the municipality intended totranslate the principles set out in the code in clear

guidelines, some of those guidelines send con-

tradicting messages to the employees. Forinstance, as corruption is a key issue in the civil

service, it was decided that the employees couldaccept no gift whatsoever. However, the code

makes one exception: because of practical reasonsthe members of the municipal executive are

allowed to accept gifts which do not exceed 45euros. Though gifts of such a magnitude obvi-

ously do not jeopardize the integrity of the exec-

utive members, this exception to the no giftrule is perceived by some employees as tolerancewith people who circumvent the rules, provided

they are powerful enough. This can result in a

cynical attitude also towards other efforts tosupport integrity in the organisation. To prevent

this some departments and city boroughs decidedto erase the exception to the no gift rule out

of their own code of conduct.Similarly, the self-evaluation shows that the

processes of responsibilisation are better inte-

grated in some organisational areas, e.g. the area

of leadership, than others, e.g. the area ofprimary processes. This outcome was no surprise

for the participants of the self-evaluation.

Presently, a lot of attention is paid to the exem-plary role of managers in stimulating responsiblebehaviour. Also the start of the Bureau of

Integrity is an outcome of several years of policymaking about stimulating responsible behaviour

within the municipality of Amsterdam. Oneof the participants nuances the relative poor

outcomes on the primary processes. When you

look at it from a general point of view theprocesses are quite well aligned with the code of

conduct. But when you make a detailed analysis,

like several departments did during the last year, youll find many points for improvement. Theoutcome of this is that the awareness of these

points for improvement first results in a lowerevaluation. More generally, the scores of the self-

evaluation are not only related to objectivefindings but also to the awareness about these

findings.

5. Reflections on the assessment method

The four case-studies, of which one has beensummarised in the previous section, provided

interesting insights about the assessment methoditself.

First, the organisations which present them-selves to customers as responsible organisations

generate an irreversible process because their cus-tomers will expect employees to account for their

actions. This implies that each employee should

be trained and equipped in order to enact thecode. Efforts to integrate the code of conduct are

more efficient when the code is made congruentwith management systems such as the quality

management system of the organisation. As theexpectations of the stakeholders continue to shift

over time, it is also necessary that efforts to inte-grate the code would be continuous.

Second, several respondents insisted that theidentification of critical activities which are

performed in the various departments is veryuseful as a point of departure for embedding



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the code, because barriers for ethical behaviour

often provide the stimuli for individual employeesto think about integrity issues. Insight in

concrete dilemma situations makes it easier todiscuss relevant integrity-supporting measures.

Moreover, an integrity policy is often introducedby the management as a reaction to unethicalbehaviour, which is caused or facilitated by such

barriers. The fear that new incidents would occuroften drives efforts to embed the code. Examples

of such barriers, named by the employees of themunicipality of Amsterdam, are cynical attitudes,

wrong behaviour by people who occupy exem-plary functions, conflicts of interests and the con-

centration of various functions within a singleperson.

Third, it is necessary to articulate both indi-vidual behaviour and collective performance in

the code of conduct, because a responsible

organisation is more than a collection of respon-sible individuals. Only when a code specifies

how the aggregated contributions of individualemployees contribute to collective results, even

on a sectoral or societal level, will the codeadequately stimulate responsible behaviour.

Examples of such aggregated contributions arethe impact of relatively small bribes on the func-

tioning of a society or the connectedness withina chain of commerce (for example the textile

industry) were problems like child labour and

poor working conditions can only be solved bya cooperation between all the participants.

Fourth, one of the organisations which tookpart in the case-studies scored lower on the

bottom-up process indicators. The respondentsclaimed that it was a conscious choice within

their organisation to focus on top-down indica-tors because some guidelines for individual

behaviour, e.g. in the case of bribing, should be

set top-down so that everyone would know whatthe organisation stands for. Though this approachmay be justified on pragmatic or other grounds

in specific cases, it should not be the case that

all the principles contained in the code ofconduct would be developed in this way. At least,

the employees should be allowed to participatein regular revisions of the code in order to

enhance the fit between the code and their prac-tical experience.

Fifth, the link between the code of conduct

and its implementation on the one hand, and the

organisational structure on the other hand, is notaddressed in this paper. It is certainly the case that

organisations which are structured as typical

informal adhocracies or machine bureaucracies,of which no one is a priori the better choice,should adopt different ways to embed responsible

behaviour within their structures. This paper pre-sented a first general attempt to measure the

embeddedness of a code of conduct by measuringits integration within the quality systems of an

organisation. Further research may be necessaryto refine this instrument to fit different types of

organisations.

6. Conclusion

In the process of setting out the structure andstarting points of this research project several

choices were made about what could and whatcould not be achieved with this project. Some

conclusions can be drawn about the results pre-sented in this paper, in the light of those choices.

A first conclusion focuses on the indicatorsdeveloped within this project. According to the

different participants in the best practice case

studies, these indicators form a coherent andcomprehensive set to measure to what extent a

code of conduct is embedded within a company.For this it turned out to be essential to take on

a process approach. Stimulating corporate socialresponsibility and embedding a code of conduct

is always a dynamic process that should go on foryears. Within this project the overall process of

embedding a code of conduct is split into six dif-ferent processes. This differentiation proved to

stimulate reflection about the strengths and weak-

nesses of an organisation on managing corporatesocial responsibility.

A second conclusion turns to the necessity ofsuch an assessment method. The limited number

of cases proved sufficient to show that themethod can be used for different purposes. When

an organisation has a code of conduct the assess-ment method results in an overview of what kind

of actions were already taken and what actionswould be valuable additions for the coming



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year(s). When different parts of an organisation

have their own codes, the assessment method canstimulate exchange of experiences about the

implementation of a code of conduct. We haveconcentrated on codes of conduct as a means

for stimulating corporate social responsibility.This choice implies that the assessment methodis only valuable for companies who already

have a code or are developing a code. At present,this means that only a select group of frontrun-

ners can use our method, because many organ-isations do not work with official codes of

conduct.In addition to those comments about our

findings, we can formulate the following remarksabout the choices we have made. A first remark

concerns the focus on codes of conduct. On theone hand, this focus relates to the empirical

observation that codes of conduct are currently

the most widely used instrument to manage cor-porate social responsibility. On the other hand,

this focus on official codes ignores the fact thatmany companies who are known to be socially

responsible do not have a code of conduct. Inthose organisations, social responsibility is con-

sidered and addressed as part of the overallculture. Of course, a code of conduct can con-

tribute to such a culture but we should not forgetthat there are other ways to stimulate corporate

social responsibility.

A second remark concerns the focus on theactions management can take to stimulate cor-

porate social responsibility. Many case studiesshow that commitment from top management is

important, though external pressure functionedas an important precondition and driving force.

External pressure has to be exerted by stake-holders, for example customers taking responsi-

bility in their shopping behaviour, politicians

threatening with legislation or lobby groupsorganising media campaigns. The focus on man-agerial action leaves out this important external

aspect. Future research could focus on possibili-

ties to include this external view within theassessment method we have developed.

Acknowledgements

This article is based on joint work by the authorsas well as Rob van Tilburg (DHV, The

Netherlands), Prof. Luc Bouckaert (Catholic

University of Leuven, Centre for Economicsand Ethics) and Dirk Ameel (Eurocadres) withinthe context of the research project Inclusive

Innovation. The authors gratefully acknowledgethe financial support of the European Union

(under Budget Heading B3-4000 Industrial rela-tions and social dialogue) and Shell, Oc, SBI,

municipality of Amsterdam and Q-Consult whomade this research project possible.

Notes

1 This code is developed by the Municipality of

Amsterdam and communicated in 2002.2 The Bureau of Integrity of Amsterdam developed

a quick scan based on twelve factors related to

breaches of integrity.

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Andr NijhofTwente University,

P.O. Box 217,7500 AE Enschede,

The Netherlands

E-mail: [email protected]

Stephan CludtsCentre for Economics and Ethics,

Catholic University of Leuven,Rogierlaan 244,B-1030 Brussels


Olaf FisscherTwente University,

P.O. Box 217,7500 AE Enschede,The Netherlands


Albertus LaanTwente University,

P.O. Box 217,7500 AE Enschede,

The NetherlandsE-mail: [email protected]


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